Case Reports and HIPAA Rules

Imagine this scenario:
You are a doctor and you just saw a very interesting patient. You would like to describe the patient as a clinical case, on a website, in order to share it with other health care professionals (some non-medical readers may visit the website as well).

Question:
Is this case report allowed under HIPAA regulations?

Answer:
Yes, if you observe certain rules.

Case Reports and HIPAA

Physicians must assure that the case report does not contain any of the 18 health information identifiers noted in the HIPAA regulations, unless authorization from the individual (s) has been obtained. The authorization is not required if neither of the 18 identifiers below are used in the case report.

List of 18 Identifiers:

1. Names;

2. All geographical subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code, if according to the current publicly available data from the Bureau of the Census: (1) The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and (2) The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.

3. All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older;

4. Phone numbers;

5. Fax numbers;

6. Electronic mail addresses;

7. Social Security numbers;

8. Medical record numbers;

9. Health plan beneficiary numbers;

10. Account numbers;

11. Certificate/license numbers;

12. Vehicle identifiers and serial numbers, including license plate numbers;

13. Device identifiers and serial numbers;

14. Web Universal Resource Locators (URLs);

15. Internet Protocol (IP) address numbers;

16. Biometric identifiers, including finger and voice prints;

17. Full face photographic images and any comparable images; and

18. Any other unique identifying number, characteristic, or code (note this does not mean the unique code assigned by the investigator to code the data)

This Website and HIPAA

All clinical cases on this website are published in strict compliance with HIPAA. Report a violation to clinicalcases@gmail.com

Patient data published on this website is modified and information from several cases may be compiled into one posting for teaching purposes and to protect patient confidentiality. Cases course and description do not follow real cases.

References:
Office for Civil Rights - HIPAA
The Human Research Protection Program - UCSF.edu
HIPAA Resources - The Privacy Rule - NIH.gov
Single Case Report Policy - Johns Hopkins Medicine
Medical Case Report Policy - Louisville.edu